The Ethics and Compliance Club is made up of the Ethics and Vigilance Director, the General Counsel, the Chief Audit Officer, ethics and vigilance managers at Group level, and compliance officers and managers from each business line. It keeps close tabs on related legislation and promotes best practices.
All Group employees have access to several reporting channels. They can refer matters to their managers, use their business unit’s local whistleblowing system or directly contact the Chief Ethics and Vigilance Department at Group level.
Employees can also decide to go through the human resources departments, health and safety representatives or employee representative bodies. They are informed of the reporting channels available to them via internal communication on the Group’s intranet, internal memos and postings, or at orientation days for new hires, company seminars and in training sessions.
VINCI has implemented an internal reporting system that allows all Group employees, but also other stakeholders, to report any behaviour or situation that infringes its Code of Ethics and Conduct, Anti-corruption Code of Conduct or rules applicable to human rights and fundamental freedoms, human health and safety, or environmental concerns, and more broadly any crime or infringement of national or international law, as well as any threat or harm to the public interest.
Employees are informed about this system through the above-mentioned internal communication channels. Stakeholders are also informed about the existence of this system through framework agreements, which include a specific clause pertaining to the subject, and in the All-round Performance Charter for Purchasing Partners (subcontractors, suppliers and service providers).
This system can be accessed via the Group intranet or website. It features (i) an online platform available worldwide 24/7, (ii) a dedicated email address, and (iii) a mailing address. The online platform VINCI Integrity can be used to report incidents safely and anonymously. The aim is to ensure that this internal reporting system remains available to all Group employees and all of its stakeholders.
The whistleblowing reporting and processing procedure, available on the Group intranet, defines how the whistleblowing process works. It is supplemented by a practical guide to internal investigations to be used by those responsible for conducting such investigations.
This procedure guarantees the confidentiality of the information collected in the context of a whistleblowing report, especially the identity of the whistleblower and of any other persons involved.
It also ensures that investigations are handled in accordance with France’s whistleblower protection legislation, and specifically Law 2022-401 of 21 March 2022, known as the Waserman law. This legislation applies to the Group, setting out the requirements for internal investigations in terms of time frames, independence and impartiality.
The governance of internal reports is coordinated by a whistleblowing committee, which collects, analyses and processes whistleblowing reports, and an investigation committee, which conducts the internal investigations. In some instances, the whistleblowing committee may propose sanctions or remediation measures for the manager at the appropriate organisational level.
The whistleblowing reporting and processing procedure also sets out how the Group receives anonymous summaries of whistleblowing reports and their results, including any sanctions or remediation measures taken.
The key employees involved in collecting and processing whistleblowing reports have received special in-person training, especially on obligations involving whistleblower protection.
Whistleblower protection
The Group pledges to protect whistleblowers and facilitators from any form of retaliation, including threats and attempts of retaliation, and to provide the persons concerned with the protection measures specified for France in Law 2016-1691 of 9 December 2016 and in Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law. These whistleblower protection measures are included in the FAQ on the VINCI Integrity platform.
